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reLAKSation no 970

Interactions: Last week, Richard Sankey, Chairman of Fisheries Management Scotland, wrote to all the District Salmon Fishery Boards and Fisheries Trusts to say that he understood that Andrew Graham Stewart, director of Salmon and Trout Conservation Scotland had contacted some board members with regard to the Salmon Interactions Working Group report. Mr Sankey added that he was extremely disappointed that S&TC had contacted some of the Fishery Boards directly without first discussing their concerns with his colleagues at Fisheries Management Scotland.

Mr Sankey also pointed out that FMS, in common with other relevant wild fisheries organisations, had adopted a consensual approach rather than the combative one taken by S&TC. He also said that FMS do not agree with the substance of the S&TC analysis of the SIWG recommendations.

This letter illustrates my own concerns about the Salmon Interactions Working Group. Whilst the various participants of SIWG may have had the best intentions in trying to resolve the issues concerning farmed and wild salmon interactions, the reality is that there will never be a solution whilst the wild sector cannot come to the table with a unified voice. The four main groups, FMS, AST, S&TC and NASCO all want the same thing, which is to safeguard the future of wild salmon and sea trout in Scotland. It surely cannot be such an ask for them to agree to work together, especially as some of them have the same patrons and presidents. Prince Charles and the Percy family are common to both S&TC and the Atlantic Salmon Trust.

My view is that the SSPO should have taken a stand that they would only be willing to talk formally, when they were able to talk to those representing the whole of the wild fish sector. SIWG should have resolved the issues once and for all but all it has done is to simply confirm the differences between various factions in the wild fish sector.

The letter highlights that Salmon & Trout Conservation Scotland are taking a different approach to other wild fish organisations yet I wonder how much their policy is reflective of  Salmon & Trout Conservation as a whole or whether it is more a personal crusade of their Scottish director. The S&TC website lists Dr Janina Gray as head of science and environmental policy and Lauren Mattingley as S&TC’s scientific officer. Lauren states on the website that scientific evidence is S&TC’s backbone, but I have yet to see any evidence submitted by Lauren or Janina in support of their campaigns against salmon farming.  Andrew Graham Stewart states on the S&TC website that ‘My primary focus is counteracting the serious damaging impacts of salmon farming’. Unfortunately, in my experience, Mr Graham Stewart is unwilling to engage or discuss his views preferring instead to direct his crusade from behind a computer keyboard. I have said many times that I find it strange that anyone who is so passionate about his subject is so reluctant to try to change minds and hearts face to face. If he is so convinced that his beliefs are right, then I fail to understand why he will not actually face those with a different view.  I can only assume that he has his narrative and is not prepared to consider any other possibility. Perhaps this is why he abused me in Trout & Salmon magazine – ‘Dr Crapper – so named because of the ‘crap’ he writes’.

Salmon & Trout Conservation have responded to the SIWG report with a 36-page document, some of which I will discuss later. I was also going to comment on the SIWG report itself but after reading Nick Joy’s view published in Fish Farmer magazine, I asked him if I could reproduce it here since he expresses his view so well. The following is his commentary:


“So here we are again, another body set up to create harmony between the wild and farmed sectors has pronounced its views. Set up just like the Tripartite Working Group, The Salmon Interactions Working Group is another body in a long history of attempts to find a brokered solution to this never ending saga of a badly run industry, full of nostalgic people longing for the catches of their youth attacking a new industry growing the king of fish. Forgive me my cynicism please, as I have seen and been involved in this area for so long, from naïve junior manager to Managing Director. The groups always start with lofty ideals of government and then descend into lobbying behind the scenes and bad blood usually caused by the same things. In the end a series of recommendations come out, which are aspirational and cause larger numbers of bureaucrats to be employed and little else.

So, let’s take a look at these “new” recommendations:

A lead body to take on regulation and planning is proposed. Well that idea is so old that I am surprised it is still alive. It makes sense but both sides will be coming at it from different directions and therefore it is unlikely to be set up. The wild sector will use their attack dogs (Salmon and Trout Conservation) to attack it as soon as it makes decision that they don’t like. Until the wild lobby agree to publicly disavow their attack dogs then there will never be a one stop shop for regulation.

It calls for local engagement and a review of Management Areas with protection of wild salmonids as the key component. Again, the two sides will expect different things from this. The farmed side will hope for agreements on a long-term basis to ensure easier management and better coordination. The wild side will want to see farm closures and much greater enforcement. They will also never sign up to a long-term agreement to a farm being in place because as soon as they have succeeded in moving their “priority” farms, they will move on to a new list.

The fundamentals that drive this difference is the ridiculous idea that the Wild salmon and Sea Trout sector are a conservation organisation. They have cleverly played themselves to government as such and both the press and government have allowed themselves to be duped. In general, in Scotland, these sort of fisheries are owned by fairly rich people, who own it and treat it, quite correctly, as an industry because that is what it is. It is a tourism industry which survives by creating a cachet, catching wild migratory fish. The catches are only significant inasmuch as they must not fall too low or become too high such that those people, who wish to dangle a fish on a line, make it fight for as long as they can and then release it, feel they are unlikely to catch enough during their allotted period. The interesting truth that also follows is that if there are too many fish and you catch one on every cast then the same people quickly become bored and will take up another pastime. The catches have been used both by the migratory salmonid angling industry to beat anyone they deem to have contributed to the decline of these wonderful fish. However here again there is a catch, forgive the pun.

Catch statistics depend on fishermen recording their catches accurately. Their relevance to a river’s true capacity have been discussed for many years. If less fishermen fish, then less fish are caught. Thus, fishing effort and accuracy of recording lie at the centre of whether catches are representative. If you think how difficult it is to get onto a West Coast river through the season, it soon becomes apparent that catch effort is not just about lazy fishermen!

So, catches may not be a good indicator. Even more so when you realise that the rateable value of a river is directly related to the number of salmon and sea trout caught on that river. Let me be even clearer, if a river catches less fish then the owner pays less rates. What this means is that a sector which sees itself as an advocacy group for a species it preys upon, has a strong incentive to underreport its catches. It is not for me to say whether they do or not, but they regularly accuse the salmon farming industry of being corrupt because of what could happen. Yet right at the centre of this debate lies an anomaly which they simply cannot deny.

Nonetheless catches for individual rivers have always been collected by government and collated into areas because they are commercially sensitive. I suppose they are, and I suppose that you could argue that you would be telling the thieves where to go to take salmon or sea trout except that these catches are reported after the fact. However, when the salmon farming industry argues that sea lice numbers and other data are commercially sensitive the wild salmon lobby suggest it is not important. The new recommendations have a very short paragraph suggesting that the angling industry will release its figures in a more useful form. I for one am not going to hold my breath waiting for it.

Oh, and just in case you worried the angling sector are looking for government support for their cause. In plain speak they are looking for government to lob some money their way. It was ever thus.

The gist of this document is that all recommendations for the farming industry appear to be in bold capitals with the wild industry’s in italics with brackets round them and an Asterix for which the note reads “not really necessary”.”


Nick Joy is not the only one to respond to the SIWG report as I have already mentioned. Salmon & Trout Conservation have also published their response. I was most interested to see that S&TC has complained that the SIWG group has extended its remit to consider the wider conservation of wild salmon and sea trout. I would have thought that a group concerned with the conservation of salmon would welcome any discussion about salmon and sea trout conservation. The reality is that S&TC are only interested in bringing about more controls on salmon farming irrespective of:

  1. Whether increased regulation actually has any impact on safeguarding wild fish or not
  2. That salmon farming only impacts on 10% of Scottish salmon catches and greater regulation on salmon farming will do nothing to help safeguard the 90% of wild salmon catches in Scotland that have no interaction with salmon farming.


S&TC say that SIWG has adopted the narrative pushed by Scottish Government and the salmon farming industry since 2018 that salmon farming is only one of a large number of pressures on wild salmonids. S&TC say that the political and public relations advantages to the fish farming industry of being able to point to a large number of other potential causes of the decline of salmon and sea trout in the aquaculture zone are clear and obvious even though there is little or no evidence for some of them having a trivial or insignificant impact to wild salmonids in the region.

By total coincidence, I recently came across an article in Trout and Salmon magazine entitled ‘Salmon in Crisis’. This included a report from a one-day international forum held on June 3rd, 1993 at Fishmongers Hall in London organised by the Salmon & Trout Association, an organisation that have now renamed themselves as Salmon & Trout Conservation.

The author of the article wrote that space allowed him to only give a brief impression of the threats to wild salmon covered in this forum. He did say that as a starting point, he should point out that world catches of Atlantic salmon had declined by 60% over the previous thirty years.

The speakers and the subjects covered included:

–           Dr David Solomon, a fisheries consultant spoke about four of the most topical and controversial threats to salmon stocks:

  1. Agricultural runoff.
  2. Acidification.
  3. Hydroelectric.
  4. Exploitation by angling.
  • Lars Hansen of NINA in Norway spoke about threats in the sea
  • Dr Nancy Harrison, RSPB spoke about the Common Fisheries Policy and industrial fishing.
  • David Paton of the ASFB (now FMS) spoke about predators and illegal fishing.
  • Michael Wigan spoke about the economic case for angling
  • Orri Vigfusson of the North Atlantic Salmon Fund spoke about High sea exploitation and net buyouts.
  • William Howarth, Professor of environmental law at the University of Kent spoke about fishery law and highlighted that a lot of fishery laws are Victorian laws with which to confront modern hazards.

Tom Barnes, then chairman of the S&TA, summed up that problems needed to be identified before they could be solved pointing to the River Dee on Scotland’s east coast. He said in 1965, 10,500 salmon were caught from the river and this number did not include fish caught by nets. In 1991, when there were no nets, the catch was just 4.100 fish.

Even the least diligent of readers will probably have noticed that five years after the collapse of the Loch Maree sea trout fishery, which forms that basis of S&TC’s campaign against salmon farming, there was one topic glaringly absent from this meeting about the critical state of salmon stocks.

S&TC readily dismiss other pressures as causing the decline of wild fish in the North West Highlands, saying only fish health and escapes have any impact. Yet, back in 1993, when salmon farming was already being blamed for the collapse of west coast stocks, the issue wasn’t even considered to be of sufficient merit to be included in this one-day international forum about the threat to wild stocks.

Of course, this meeting took place twenty-seven years ago and a lot of water has passed under the bridge since then. Much more recently, the North Atlantic Salmon Conservation Organisation (NASCO) held its 36th Annual Meeting in Tromsø from 5th to 7th June 2019.

As part of the programme, a group of NGOs submitted a document CNL (19)43 to the Council. The document is about the impacts of salmon farming. The third paragraph of this document states:

“The NASCO NGOs recognise that the impacts arising from aquaculture represent only one of a number of pressures that salmon face across their native range. It is important that these impacts are prioritised and addressed.”

What is most interesting about this document is the list of participating NGO’s and their representatives who have signed up to the document. They include Salmon & Trout Conservation Scotland and their director Andrew Graham Stewart as well as Salmon & Trout Conservation UK and their then Chief Executive Paul Knight who is identified by the ** as being the group co-chair.

It’s worth repeating what the group said in their submission:

“The NASCO NGOs recognise that the impacts arising from aquaculture represent only one of a number of pressures that salmon face across their native range,” By comparison, the S&TC response to the SIWG report states:

Many (of these pressures) do not apply, greatly or at all, to rivers in the aquaculture zone, or are of far less significance to wild salmonids that fish-farm related impacts. There is little or no evidence for some of them having anything more than a trivial or insignificant impact to wild salmonids in the aquaculture zone of the west of Scotland and the islands.

S&TC also state that “a cursory look at the list above will identify two serious pressures on the west coast and in the islands that are very strongly fish-farm related” in their opinion.

I would argue that the time has come for Andrew Graham Stewart and Salmon & Trout Conservation to decide on their future strategy. They can either join the other organisations at the negotiating table and speak with one unified voice or become a completely irrelevant fringe organisation ignored by everyone.

I would also suggest that if and when the wild sector does unify, it must also be willing to engage in a wide-ranging scientific discussion considering all the evidence not just the parts that suit them. If wild fish stocks across all of Scotland are to be secured for the future, then there must be more open debate.



Salmon & Trout Conservation’s Communication Consultant also posts on Facebook under his own name. Clearly, his comments reflect S&TC’s views otherwise they would surely tell him to stop posting or even disassociate themselves from his views.

Following the publication of the SIWG report, he posted that:

‘You can have wild salmon or you can have open cage salmon farms. You can’t have both. You must pick a side.’

And more recently:

Pick your side. Salmon farmers or wild salmon?

This ends here, now. Decision time for the Scottish Government. Decision time for all of us.’

Whilst he is totally wrong that you have can have salmon farms or wild salmon but not both as the Grade 1 River Ewe clearly demonstrates he is right that it is decision time. It is time for Salmon & Trout Conservation Scotland to join with others to help safeguard the future of wild salmon with a unified voice or else be an outcast fringe irrelevance. The decision is theirs.